BACKGROUND: Congress and the FTC have taken special steps to assure that children under 13 years of age don’t share their personal information on the Internet without the express approval of their parents. Congress passed the Children’s Online Privacy Protection Act (“COPPA”) in 1998 and the FTC wrote a rule in 1999 implementing the law, which was revised in 2012. It is the express intention of D.M. CUMBO, LLC and its members to be in strict compliance with COPPA.
-D.M. Cumbo, LLC won’t require a child to disclose more information than is reasonably necessary to participate in an activity;
you may review your child’s personal information, direct D.M. Cumbo, LLC to delete it, and refuse to allow any further collection or use of your child’s information;
you can agree to the collection and use of their child’s information, but still not allow disclosure to third parties unless that is part of the service (for example, social networking);
you may exercise your rights by contacting D.M. Cumbo. LLC using the following information: email: firstname.lastname@example.org
In addition, D.M. Cumbo, LLC acknowledges that even if parents have agreed to allow collection of personal information of their kids, parents may, at any time, review the personal information collected from their child, revoke consent and refuse the further use or collection of personal information from their child, and ensure deletion of their child’s personal information.
D.M. Cumbo, LLC implements reasonable procedures to protect the security of children’s personal information. It does not disclose personal information to any third parties. D.M. Cumbo, LLC minimizes any collection of children's personal information. It holds onto information only as long as is reasonably necessary for the purpose for which it was collected. D.M. Cumbo, LLC will securely dispose of it once it no longer has a legitimate reason for retaining it.
D.M. Cumbo, LLC will provide direct notice to parents and obtain verifiable parental consent, with limited exceptions, before collecting personal information online from children;
- Give parents the choice of consenting to the operator’s collection and internal use of a child’s information, but prohibiting the operator from disclosing that information to third parties (unless disclosure is integral to the site or service, in which case, this must be made clear to parents);
- Provide parents access to their child's personal information to review and/or have the information deleted;
- Give parents the opportunity to prevent further use or online collection of a child's personal information;
- Maintain the confidentiality, security, and integrity of information they collect from children, including by taking reasonable steps to release such information only to parties capable of maintaining its confidentiality and security; and
- Retain personal information collected online from a child for only as long as is necessary to fulfill the purpose for which it was collected and delete the information using reasonable measures to protect against its unauthorized access or use.
PERSONAL INFORMATION: Personal information may include:
· First and last name;
· A home or other physical address including street name and name of a city or town;
· Online contact information;
· A screen or user name that functions as online contact information;
· A telephone number;
· A persistent identifier that can be used to recognize a user over time and across different websites or online services;
· A photograph, video, or audio file, where such file contains a child’s image or voice;
· Geolocation information sufficient to identify street name and name of a city or town; or
· Information concerning the child or the parents of that child that the operator collects online from the child and combined with an identifier described above.